sec04 2012 evidence for inadequacy of the standards 02 aug 2013

8/22/2019 Sec04 2012 Evidence for Inadequacy of the Standards 02 AUG 2013

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SECTION 4

Evidence for Inadequacy of the Standards

Cindy Sage, MA

Sage Associates

Santa Barbara, CA USA

Prepared for the BioInitiative Working Group

September 2012


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I. Introduction

Evidence for judging the adequacy (or inadequacy) of the existing ICNIRP and IEEE

C95.1 radiofrequency radiation standards can be taken from many relevant sources. The

ICNIRP standards are similar to the IEEE (except for the new C95.1 -2006) revisions by

IEEE SC-4), and these discussions can be used to evaluate both sets of public exposure

standards for adequacy (or inadequacy).

An important screen for assessment of how review bodies conduct their science reviews

and resulting conclusions on the adequacy of ELF and RF exposure limits depends on

embedded assumptions. The singularly most important embedded assumption is whether

these bodies assume from the beginning that only conclusive scientific evidence (proof)

will be sufficient to warrant change; or whether actions should be taken on the basis of a

growing body of evidence which provides early but consequential warning of (but not yet

proof) of possible risks.

As a result of current international research and scientific discussion on whether the

prevailing RF and ELF standards are adequate for protection of public health, there are

many recent developments prior to 2007 to provide valuable background on the

uncertainty about whether current standards adequately protect the public. Since 2007,

there are important new milestone publications that underscore the critical need to update

public safety limits. These newer documents calling for review and updating are based

on a deluge of new scientific studies reporting effects at non-thermal, low-intensity ELF

and RF exposure levels. There is little doubt that bioeffects and adverse health effects are

occurring at lower-than-safety limit levels, meaning the existing protections are

inadequate.

II. United States Government Accountability Office

The US Government Accountability Office published a report in 2012 urging the US

Federal Communications Commission to revisit the outdated safety standards for the

exposures from wireless devices. (US GAO, 2012)


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The rapid adoption of mobile phones has occurred amidst controversy over whether the

technology poses a risk to human health as a result of long-term exposure to RF energy

from mobile phone use. FCC and FDA share regulatory responsibilities for mobile

phones. GAO was asked to examine several issues related to mobile phone health effects

and regulation. Specifically, this report addresses:

(1) what is known about the health effects of RF energy from mobile phones

and what are current research activities,(2) how FCC set the RF energy exposure limit for mobile phones, and

(3) federal agency and industry actions to inform the public about healthissues related to mobile phones, among other things.

GAO reviewed scientific research; interviewed experts in fields such as public health andengineering, officials from federal agencies, and representatives of academic institutions,

consumer groups, and the mobile phone industry; reviewed mobile phone testing and

certification regulations and guidance; and reviewed relevant federal agency websites and

mobile phone user manuals.

The Report noted that the FCC's RF energy exposure limit may not reflect the latest

research. Redundant and overlapping jurisdiction over the setting of public safety limits

is highlighted where the GAO Report notes:

"FCC told GAO that it relies on the guidance of federal health and safetyagencies when determining the RF energy exposure limit, and to date, none of

these agencies have advised FCC to change the limit. However, FCC has notformally asked these agencies for a reassessment. By not formally reassessing

it's current limit, FCC cannot ensure it is using a limit that reflects the latestresearch on RF energy exposure. FCC has also not reassessed it's testing

requirements to ensure that they identify the maximum RF energy exposure auser could experience. Some consumers may use mobile phones against the

body, which FCC does not currently test, and could result in RF energyexposure higher than the FCC limit." (US GAO, 2012)

The GAO Report recommends to the FCC that it formally reassess, and, if appropriate,

change it's current RF energy exposure limit and mobile phone testing requirements

related to likely usage configurations, particularly when phones are held against the body.


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FCC noted that a draft document that is now under consideration by the FCC has the

potential to address GAO's recommendations. (US GAO, 2012)

III. International Agency for Research on Cancer - World Health Organization

Classifies Radiofrequency Radiation as 2B Possible Human Carcinogen

In 2011, a group of 30 researchers, scientists and medical doctors were invited to

participate in an assessment of the scientific literature on radiofrequency radiation

carcinogenicity in Lyon, France. Under the auspices of IARC, they conducted a

comprehensive scientific assessment of RF studies and determined:

"In view of the limited evidence in humans and in experimental animals, the

Working Group classified RF-EMF as possibly carcinogenic tohumans (Group 2B). This evaluation was supported by a large majority ofWorking Group members." (Baan et al, 2011)

"(T)he Working Group concluded that the (Interphone Final Report) findings

could not be dismissed as reflecting bias alone, and that a causal interpretationbetween mobile phone RF-EMF exposure and glioma is possible. A similar

conclusion was drawn from these two studies for acoustic neuroma, although thecase numbers were substantially smaller than for glioma." (Baan et al, 2011)

It is important to recognize that the IARC RF Working Group did not find the evidence

insufficient to classify (Group 3) or not a carcinogen (Group 4). Both of these possible

outcomes to the scientific assessment could have rendered a substantially weaker

conclusion. Where there has been the necessity of a virtual scientific paradigm shift to

accommodate ANY consideration of both ELF-EMF and RFR to the status where

legitimate scientific attention is achieved is a notable achievement. There is a very high

bar set to show that non-chemical carcinogens warrant IARC carcinogenicity evaluation -

it greatly exceeds that necessary for chemicals and other toxins.

IV. World Health OrganizationINTERPHONE Study on Mobile Phone Cancer

Risk

In 2010, the World Health Organization released the final results of it's investigation on


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cell phones and cancer. (INTERPHONE Study Group, 2010) The ten-year long World

Health OrganizationINTERPHONE Study confirms previous reports showing what many

experts have warnedthat regular use of a cell phone by adults can significantly increase

the risk of glioma by 40% with 1640 hours or more of use (this is about one-half hour per

day over ten years). Tumors were more likely to occur on the side of the head most used

for calling. The risk increases to 96% for adults with ipsilateral cell phone use (when the

cell phone is used predominantly on one side of the head). The study appears in the

International Journal of Epidemiology. Thirteen teams from countries around the world

combined their results. Only the glioma findings were released (final results on acoustic

neuroma and parotid tumors are not yet published.

A comprehensive and technically reliable description of theINTERPHONEstudy

findings is provided within the International Agency for Research on Cancer, 2011 RF

Monograph as part of the publication in Lancet Oncology on IARC's classification of

radiofrequency radiation as a 2B Possible Human Carcinogen. Results of the

INTERPHONEStudy were highly scrutinized by IARC, and influenced the classification

of RF based on the cell phone-brain cancer findings ofINTERPHONE.

From Baan et al, 2011:

"The INTERPHONE study, a multi-centre case-control study, is the largestinvestigation so far of mobile phone use and brain tumours, including glioma,

acoustic neuroma, and meningioma.The pooled analysis included 2708 glioma casesand 2972controls(participation rates64% and 53%, respectively). Comparing thosewho ever used mobile phones with those who never did yielded an odds ratio (OR)

of 081 (95% CI 070094). In terms of cumulative call time, ORs were uniformly

below or close to unity for all deciles of exposure except the highest decile (>1640 h

of use), for which the OR for glioma was 140 (95% CI 103189). There wassuggestion of an increased risk for ipsilateral exposure(on the same side of the headas the tumour) and for tumours in the temporal lobe, where RF exposure is highest.

Associations between glioma and cumulative specific energy absorbed at the tumour

location were examined in a subset of 553 cases that had estimated RF doses.10 TheOR for glioma increased with increasing RF dose for exposures 7 years or more

before diagnosis, whereas there was no association with estimated dose forexposures less than 7 years before diagnosis.

A Swedish research group did a pooled analysis of two very similar studies of

associations between mobile and cordless phone use and glioma, acoustic neuroma,and meningioma.9 The analysis included 1148 glioma cases (ascertained 1997

2003) and 2438 controls,obtained through cancer and population registries,


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respectively. Self-administered mailed questionnaires were followed by telephone

interviews to obtain information on the exposures and covariates of interest,including use of mobile and cordless phones (response rates 85% and 84%,

respectively). Participants who had used a mobile phone for more than 1 year had

an OR for glioma of 1.3 (95% CI 1116). The OR increased with increasing timesince first use and with total call time, reaching 3.2 (2051) for more than 2000 h

of use. Ipsilateral use of the mobile phone was associated with higher risk. Similarfindings were reported for use of cordless phones.

Although both the INTERPHONE study and the Swedish pooled analysis are

susceptible to biasdue to recall error and selection for participationtheWorking Group concluded that the findings could not be dismissed as reflecting biasalone, and that a causal interpretation between mobile phone RF-EMF exposure and

glioma is possible. A similar conclusion was drawn from these two studies for

acoustic neuroma, although the case numbers were substantially smaller than for

glioma. Additionally, a study from Japan (11) found some evidence of an increasedrisk for acoustic neuroma associated with ipsilateral mobile phone use.

(Baan et al, 2011)

No that no increased risk was detected overall. But this is not unexpected. No

exposures to carcinogens that cause solid tumors like brain cancer or lung cancers, for

example from tobacco and asbestos have ever been shown to significantly increase cancer

risk in people with such short duration of exposure. The latency period for brain cancer

is 15-30 years.

The final INTERPHONE results support findings of several research groups who have

published studies reporting that continuing use of a mobile phone increases risk of brain

cancer. We would not expect to see substantially increased brain tumor risk for most

cancer-causing agents except in the longer term (10 year and longer) as is the case here in

the population of regular cell phone users. Further, the participants included in this study

were 30-59 years old, excluding younger and older users. Use of cordless phones was

neglected in the analysis. Radiofrequency radiation from some cordless phones can be as

high as mobile phones in some countries, so excluding such use would underestimate the

risk for brain tumors and other cancers.

For public health experts and members of the public who looked to IARC for further

clarification of the scope of this 2B Possible Human Carcinogen designation, Dr. Baan

replied to informal queries that:


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"Although the key information came from mobile telephone use, theWorking Group considered that the three types of exposure entail

basically the same type of radiation, and decided to make an overallevaluation on RF-EMF, covering the whole radiofrequency region of the

electromagnetic spectrum.

In support of this, information from studies with experimental animalsshowed that effects on cancer incidence and cancer latency were seen

with exposures to different frequencies within the RF region.

So the classification 2B, possibly carcinogenic, holds for all types ofradiation within the radiofrequency part of the electromagnetic

spectrum, including the radiation emitted by base-station antennas, radio/TV towers, radar, Wi-Fi, smart meters, etc." (Personal communication of Dr.

Robert Baan to Connie Hudson, August 29, 2011)

V. President's Cancer Panel Report of 2010

The United States President's Cancer Panel Report (2010) includes important and

unprecedented recognition of non-ionizing radiation as a possible carcinogen deserving

of further research and possible public health action. The Report found "the true burden

of environmentally induced cancers has been grossly underestimated" and strongly urged

action to reduce peoples' widespread exposures to carcinogens. The 240-page report

issued for 2008-2009 by a panel of experts that report to the US president indicate that

environmental factors are underestimated in cancer prevention. The Report specifically

addresses the link between cell phones and cancer. The Panel recommends that people

reduce their cell phone exposure, even when absolute proof of harm is not yet available.

Research Recommended by Presidents Cancer Panel

Resolve controversies regarding the safety or harm oflow doses of various formsof radiation in adults and children. Identify circumstances under which low- dose

radiation may have a hormetic effect.

Develop radiation dose and risk estimates that better reflect the current and futureU.S. population. Existing dose and risk estimates have been based on adult males;

estimates should account for population diversity, including children. In addition,develop medical radiation risk estimates that are not based on acute doses received

by atomic bomb survivors.


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Expand research on possible harmful effects of cell phone use, especially inchildren. Cell phone use still is relatively recent, and studies to date have had mixed

findings; most involve users of older equipment. Findings from cohort studies nowunderway are anticipated, but longer-term studies of individuals using current

equipment are needed.

Conduct additional research on possible links between electromagnetic fields(EMF) and cancer; identify mechanism(s) of EMF carcinogenesis.

Monitor changing patterns of radiation exposure.

Raise the priority of and investment in research to develop non-toxic products

anD processes.

Develop, test, and evaluate prevention communication strategies and

interventions, especially in high-risk occupations and populations.

(National Cancer Institute, 2010)

VI. World Health Organization Research Agenda for Radiofrequency Fields (2010)

In 2010, the WHO produced a research agenda to address growing scientific questions

and public concern about health effects of radiofrequency radiation, particularly with the

explosive rise in exposures from new telecommunications technologies. It replaced a

2006 research agenda developed by the International EMF Project.

"Telecommunication technologies based on radiofrequency (RF) transmission, suchas radio and television, have been in widespread use for many decades. However,

there are numerous new applications for the broadcast and reception of RF wavesand the use of RF devices such as mobile phones is now ubiquitous.

The attendant increased public exposure to RF fields has made its effects on

human health a topic of concern for scientists and the general public.(emphasis added)

To respond to these concerns, an important research effort has been mounted over

the past decade and many specific questions about potential health effects of RFfields have already been investigated by scientists around the world. Nonethe-

less, several areas still warrant further investigation and the rapid evolution oftechnology in this field is raising new questions." (WHO, 2010)

"This Research Agenda is developed ahead of the major hazard/health risk evalu-


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ations that the IARC and WHO are due to carry out over the next two years. Itfocuses on identifying short- and long-term research needs that will enable more

complete health risk assessments to be undertaken and communicated more ef-fectively to the public." (WHO, 2010)

Recommendations of the WHO Research Agenda for Radiofrequency Fields are as

follows. This section is necessarily extensive to document the advice of experts at WHO

by 2010 in recognizing radiofrequency radiation has the potential to result in global

health impacts; even if very slow to implement precautionary advice to the European

Commission and member countries.

Priority: Epidemiology

High- Prospective cohort studies of children and adolescents with outcomes including

behavioural and neurological disorders and cancer

Rationale: As yet, little research has been conducted in children and adolescents and it isstill an open question whether children are more susceptible to Rf EMF since the brain

continues to develop during childhood and adolescence. also, children are starting to usemobile phones at a younger age. given the existence of large-scale cohort studies of

mothers and children with follow-up started during or before pregnancy, an Rf sourcescomponent could be added at a reasonably low cost. Billing records for mobile phones

are not valid for children, therefore the prospective collection of exposure data is needed.for neuropsychological studies, one challenge is to distinguish the training of motor

and neuropsychological skills caused by the use of a mobile phone from the effects ofthe Rf field. any future study should try to address this issue. in any case it should be of

longitudinal design, thereby allowing the study of several outcomes and changes intechnology and the use of mobile phones as well as other sources of Rf eMf exposure,

such as wireless laptops.

High - Monitoring of brain tumour incidence trends through well-established population-based cancer registries, if possible combined with population exposure data

Rationale: If there is a substantial risk associated with mobile phone use, it should be

observable in data sources of good quality. such time trend analyses can be performedquite quickly and inexpensively. By using modern statistical techniques for analysing

population data it should be possible to link changes in exposure prevalence in thepopulation to the incidence of brain tumours and, if high-quality surveillance data are

available, the incidence of other diseases at the population level. given the shortcomingsin the exposure assessment and participation of previous studies based on individual data,

an ecological study would have benefits that may outweigh its limitations.


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Other - case-control studies of neurological diseases provided that objective exposuredata and confounder data are available and reasonable participation is achieved

Rationale: Neurological endpoints, such as alzheimer disease and Parkinson disease, may

be as biologically plausible as brain cancer and an increased risk would have a major

public health impact. This study could give an early warning sign that can be elaboratedfurther in the prospective cohort studies. an analysis of time-trends in neurologicaldisease could also serve as an early warning sign. However, a feasibility study would be

necessary in order to determine whether a good quality case-control study could becarried out.

Priority: Human studies

High - further RF EMf provocation studies on children of different ages

Rationale: current research has focused primarily on adolescents; very little is known

about possible effects in younger children. longitudinal testing at different ages, for ex-ample by studying children already participating in current cohort studies, is

recommended. This would allow consideration of the influence of potentiallyconfounding factors such as lifestyle.

High - Provocation studies to identify neurobiological mechanisms underlying possible

effects of RF on brain function, including sleep and resting EEG

Rationale: These studies should include validation of these effects using a range of brainimaging methods. They should also include studies investigating possible thresholds and

dose-response relationships at higher exposure levels such as those encountered duringoccupational exposure.

Priority: Animal studies

High - Effects of early-life and prenatal RF exposure on development and behaviour

Rationale: There is still a paucity of information concerning the effects of prenatal and

early life exposure to RF EMf on subsequent development and behaviour. Such studiesare regarded as important because of the widespread use of mobile phones by children

and the increasing exposure to other RF sources such as wireless local area networks(Wlans) and the reported effects of RF EMf on the adult EEG. further study is required

which should include partial (head only) exposure to mobile phones at relatively highspecific absorption rate (SAR) levels.

High - effects of RF exposure on ageing and neurodegenerative diseases

Rationale: age-related diseases, especially neurodegenerative diseases of the brain such

as alzheimer disease and Parkinson disease, are increasingly prevalent and are thereforean important public health issue. Mobile phone use typically involves repeated Rf eMf


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exposure of the brain; a recent study has suggested that this type of exposure could affectalzheimer disease in a transgenic mouse model for this condition (arendash et al., 2010).

There are a few ongoing studies of possible Rf eMf effects on neurodegenerative diseasesbut further studies are required to investigate this subject more fully.

Other research needs - Effects of RF exposure on reproductive organs

Rationale: The available data concerning possible effects of Rf eMf from mobile phones

on male fertility are inconsistent and their quality and exposure assessments are weak. invivo studies on fertility should consider effects on both males and females and investigate

a range of relevant endpoints including Rf eMf effects on the development and functionof the endocrine system.

Priority: Cellular studies

Other - Identify optimal sets of experimental tests to detect cellular response after

exposure to new RF technologies and co-exposures of RF EMF with environmentalagents

Rationale: a number of in vitro studies investigating the effects of exposure to mobile

phone frequencies/signals, or co-exposures of RF EMf with chemical or physical agents,have been published in the last fifteen years. Results obtained have been inconsistent and

contradictory, not least because of the use of a large variety of cell types and studyapproaches. a set of highly sensitive, well-harmonized cellular and molecular methods

should be developed in order to screen the toxic potential of new types of RF signals usedin new technologies and of co-exposures of RF EMf and environmental agents

especially those suspected to have toxic effects. This research must be multicentred inorder to allow the widest possible acceptance and application of this screening tool.

Other - further studies on the influence of genetic background and cell type: possible

effects of mobile phone type Rf exposure on a variety of cell types using newer, moresensitive methods less susceptible to artefact and/or bias

Rationale: More rigorous quantitative methods should be employed in the evaluation of

positive results that suggest a specific cell type response, e.g. of embryonic cells (Czyz etal., 2004; Franzellitti et al., 2010), raising the possibility that RF impacts specific cell

subpopulations or cell types. These studies should include a variety of cell types such asstem cells and cells with altered genetic backgrounds.

Priority: Mechanisms: none

Priority: Dosimetry

High - Assess characteristic RF EMF emissions, exposure scenarios and corresponding

exposure levels for new and emerging RF technologies; also for changes in the use ofestablished technologies


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Rationale: The work should address the latest developments in areas such as mobile/cord-

less phones, wireless data networking, asset tracking and identification, wireless transferof electrical power and body imaging/scanners. it should also consider the possible

combined effect of exposure to multiple sources. This will allow exposures from new

devices/scenarios to be compared with those that are more familiar and with exposureguidelines for risk communication purposes. This information will also be of value forexposure assessment in epidemiological studies and in the design of biological exposure

systems.

High - quantify personal exposures from a range of RF sources and identify thedeterminants of exposure in the general population

Rationale: The quantification of personal exposure from a range of RF sources will

provide valuable information for risk assessment and communication, and for the

development of future epidemiological research. it is particularly useful for global

exposure assessment in view of the upcoming WHO health risk assessment. The studywill also provide baseline data for identification of any changes in the level of exposure

and the dominant contributing factors over time. subgroup analyses should be carried outto identify any influence from demographic aspects of the user as well as the

microenvironment in which the exposure occurs. exposure metrics should also beconsidered, especially in combining localized exposures from body-worn devices and

whole-body exposures.

Other research needs - Monitoring of personal exposure of Rf workers

Rationale: The exposure patterns of both workers and the general public changecontinuously, mainly due to the development of new RF technologies. However, workers

encounter industrial sources and exposure situations that lead to much higher energydeposition in the body. When epidemiological studies on RF workers are performed, it is

imperative to monitor adequately their RF exposure. new instruments are needed toaddress the lack of adequate measurement tools for evaluating this type of exposure e.g.

portable devices suitable for measuring different frequencies and waveforms. in addition,a study of the feasibility of monitoring the personal exposure of RF workers is required

for future epidemiological studies. such studies would be facilitated by the production ofa job exposure matrix (JeM) for RF workersin which job designations can be

characterized by their exposure. (WHO, 2010)


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VII. National Academy of Sciences, National Research Council (2008)

The U.S. Food and Drug Administration (FDA) of the Department of Health and Human

Services asked the National Academies to organize a workshop of national and

international experts to identify research needs and gaps in knowledge of biological

effects and adverse health outcomes of exposure to radiofrequency (RF) energy from

wireless communications devices. To accomplish this task, the National Academies

appointed a seven member committee to plan the workshop.1

Following the workshop, the committee was asked to issue a report based on the

presentations and discussions at the workshop that identified research needs and current

gaps in knowledge. The committees task did not include the evaluation of health effectsor the generation of recommendations relating to how the identified research needs

should be met.

For the purposes of this report, the committee defines research needs as research that will

increase our understanding of the potential adverse effects of RF energy on humans.

Research gaps are defined as areas of research where the committee judges that scientific

data that have potential value are presently lacking, but that closing of these gaps is either

ongoing and results should be awaited before judgments are made on further research

needs, or the gaps are not judged by the committee to be of as high a priority with respect

to directly addressing health concerns at this time.

1. Committee on Identification of Research Needs Relating to Potential Biological or

Adverse Health Effects of Wireless Communications Devices.

These needs and gaps are committee judgments derived from the workshop presentations

and discussions, and the report does not necessarily reflect the views of the FDA,

individual workshop speakers, or other workshop participants.


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The committee judged that important research needs included, in order of appearance in

the text, the following:

Characterization of exposure to juveniles, children, pregnant women, and fetuses

from personal wireless devices and RF fields from base station antennas.

Characterization of radiated electromagnetic fields for typical multiple- element

base station antennas and exposures to affected individuals.

Characterization of the dosimetry of evolving antenna configurations for cellphones and text messaging devices.

Prospective epidemiologic cohort studies of children and pregnant women.

Epidemiologic case-control studies and childhood cancers, including brain

cancer.

Prospective epidemiologic cohort studies of adults in a general population andretrospective cohorts with medium to high occupational exposures.

Human laboratory studies that focus onpossible adverse effects on

electroencephalography2 activity and that include a sufficient number of subjects.

Investigation of the effect of RF electromagnetic fields on neural networks.

Evaluation of doses occurring on the microscopic level.

Additional experimental research focused on the identification of potentialbiophysical and biochemical/molecular mechanisms of RF action.

(NAS-NRC, 2008)

VIII. World Health Organization Draft Framework for Electromagnetic Fields

The International EMF Project was established by WHO in 1996. Its mission was to

pool resources and knowledge concerning the effects ofexposure to EMF and make a

concerted effort to identify gaps in knowledge, recommend focused research programmes

that allow better health risk assessments to be made, conduct updated critical reviews of

the scientific literature, and work towards an international consensus and solutions on

the health concerns. (WHO September 1996 Press Release - Welcome to the

International EMF Project)


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The stated role of the WHO Precautionary Framework on EMF Health Risk Research

(Radiation and Environment Health) has termed its objectives as follows;

to anticipate and respond to possible threats before introduction ofan agent or technology

to address public concerns that an uncertain health risk is minimized

after introduction of an agent to develop and select options proportional to the degree of scientific

certainty, the severity of harm, the size and nature of the affectedpopulation and the cost.

The role of WHO is advisory only to the countries of Europe but it is an important

function and can significantly affect decision-making on public health issues. It provides

analysis and recommendations on various topics of health and environment, for

consideration by member countries of the EU. Given the EU Article 174 policy requires

a precautionary approach to judging health and environmental risks, and given that the

charter of WHO is to serve the needs of the EU, one would think it essential that the

WHO EMF Program health criteria results should be guided by and t ailored to

compliance with Article 174. This needs to occur in the assessment of the scientific

literature (e.g., not requiring studies to provide scientific proof or causal scientific

evidence but paying attention to and acting on the evidence, and the trend of the evidence

at hand) and in its environmental health criteria recommendations. If the WHO EMF

Program instead chooses to use the definitions of adverse impact and risk based on

reacting to nothing short of conclusive scientific evidence, it fails to comply with the

over-arching EU principle of health.

The World Health Organization has issued a draft framework to address the adequacy of

scientific information, and accepted definitions of bioeffects, adverse health effect and

hazard (WHO EMF Program Framework for Developing EMF Standards, Draft, October

2003). These definitions are not subject to the whim of organizations preparing public

exposure standard recommendations. The WHO definition states that:

(A)nnoyance or discomforts caused by EMF exposure may not be pathologicalper se, but, if substantiated, can affect the physical and mental well-being of a


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person and the resultant effect may be considered as an adverse health effect. Ahealth effect is thus defined as a biological effect that is detrimental to health or

well-being. According to the WHO Constitution, health is a state of completephysical, mental, and social well-being and not merely the absence of disease or

infirmity. www.who.int/peh-

emf

IX. The European Union Treaties Article 174

The EU policy (Article 174-2) requires that the precautionary principle be the basis for

environmental protection for the public, and that protecting public health and taking

preventative action before certainty of harm is proven is the foundation of the

Precautionary Principle. It is directly counter to the principles used by ICNIRP and

IEEE in developing their recommendations for exposure standards. Both bodies requireproof of adverse effect and risk before amending the exposure standards; this Treaty

requires action to protect the public when a reasonable suspicion of risk exists

(precautionary action).

Article 174 (2) [ex Article 130r]

1. Community policy on the environment shall contribute to pursuit of the following

objectives:

preserving, protecting and improving the quality of the environment;protecting human health;prudent and rational utilisation of natural resources;

promoting measures at international level to deal with regional or worldwideenvironmental problems.

2. Community policy on the environment shall aim at a high level of protection taking

into account the diversity of situations in the various regions of the Community. It shallbe based on the precautionary principle and on the principles that preventive action

should be taken, that environmental damage should as a priority be rectified at source andthat the polluter should pay. In this context, harmonization measures answering

environmental protection requirements shall include, where appropriate, as a safeguardclause allowing Member States to take provisional measures, for non-economic

environmental reasons, subject to a Community inspection procedure.

3. In preparing its policy on the environment, the Community shall take account of:

available scientific and technical data;environmental conditions in the various regions of the Community;
http://www.who.int/peh-emfhttp://www.who.int/peh-emfhttp://www.who.int/peh-emfhttp://www.who.int/peh-emfhttp://www.who.int/peh-emf


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the potential benefits and costs of action or lack of action;the economic and social development of the Community as a whole and the balanced

development of its regions.

http://www.law.harvard.edu/library/services/research/guides/international/eu/eu_legal_re

search_treaties.php

X. WHO ELF Environmental Health Criteria Monograph, June 2007

In 2007. the WHO EMF Program released its ELF Health Criteria Monograph and held a

workshop in Geneva, Switzerland June 20-21st.

ELF Health Criteria Monograph

12.6 Conclusions

Acute biological effects have been established for exposure to ELF electric andmagnetic fields in the frequency range up to 100 kHz that may have adverse

consequences on health. Therefore, exposure limits are needed. International guidelinesexist that have addressed this issue. Compliance with these guidelines provides adequate

protection.

Consistent epidemiological evidence suggests that chronic low-intensity ELF

magnetic field exposure is associated with an increased risk of childhood leukaemia.

However, the evidence for a causal relationship is limited, therefore exposure limits

based upon epidemiological evidence are not recommended, but some precautionary

measures are warranted. (emphasis added).

The Monograph finds no reason to change the designation of EMF as a 2B (Possible)

Human Carcinogen as defined by the International Agency for Cancer Research (IARC).In finding that ELF-EMF is classifiable as a possible carcinogen, it is inconsistent to

conclude that no change in the exposure limits is warranted. If the Monograph confirms,as other review bodies have, that childhood leukemia occurs at least as low as the 3 mG

to 4 mG exposure range, then ICNIRP limits of 1000 mG for 50 Hz and 60 Hz ELFexposures are clearly too high and pose a risk to the health of children.

The WHO Fact Sheet summarizes some of the Monograph findings but adds further

recommendations.

Potential long-term effects

Much of the scientific research examining long-term risks from ELF magnetic fieldexposure has focused on childhood leukaemia. In 2002, IARC published a monograph

classifying ELF magnetic fields as "possibly carcinogenic to humans. This classificationwas based on pooled analyses of epidemiological studies demonstrating a consistent


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pattern of a two-fold increase in childhood leukaemia associated with average exposureto residential power-frequency magnetic field above 0.3 to 0.4 T. The Task Group

concluded that additional studies since then do not alter the status of thisclassification. (emphasis added)

International exposure guidelines

Health effects related to short-term, high-level exposure have been established and form

the basis of two international exposure limit guidelines (ICNIRP, 1998; IEEE, 2002). Atpresent, these bodies consider the scientific evidence related to possible health effects

from long-term, low-level exposure to ELF fields insufficient to justify lowering thesequantitative exposure limits.

Regarding long-term effects, given the weakness of the evidence for a link between

exposure to ELF magnetic fields and childhood leukaemia, the benefits of exposurereduction on health are unclear. In view of this situation, the following recommendations

are given:

1) Government and industry should monitor science and promote researchprogrammes to further reduce the uncertainty of the scientific evidence on the

health effects of ELF field exposure. Through the ELF risk assessment process,gaps in knowledge have been identified and these form the basis of a new research

agenda.

2) Member States are encouraged to establish effective and open communicationprogrammes with all stakeholders to enable informed decision-making. These may

include improving coordination and consultation among industry, localgovernment, and citizens in the planning process for ELF EMF-emitting facilities.

3) When constructing new facilities and designing new equipment, including

appliances, low-cost ways of reducing exposures may be explored. Appropriateexposure reduction measures will vary from one country to another. However,

policies based on the adoption of arbitrary low exposure limits are not warranted.

The last bullet in the WHO ELF Fact Sheet does not come from the Monograph, nor is itconsistent with conclusions of the Monograph. The Monograph does call for prudent

avoidance measures, one of which could reasonably be to establish numeric planningtargets or interim limits for new and upgraded transmission lines and appliances used by

children, for example. Countries should not be dissuaded by WHO staff, who unlike theauthors of the Monograph, go too far in defining appropriate boundaries for countries that

may wish to implement prudent avoidance in ways that best suit their population needs,expectations and resources. www.who.int/peh-emf/project/en
http://www.who.int/peh-emf/project/enhttp://www.who.int/peh-emf/project/enhttp://www.who.int/peh-emf/project/en


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XI. World Health Organization Report on Childrens Health and Environment

Environmental Issue Report Number 29 from the World Health Organization (2002)

cautions about the effects of radiofrequency radiation on childrens health. As part of a

publication on Childrens Health and Environment: A Review of Evidence the WorldHealth Organization (WHO) wrote:

The possible adverse health effects in children associated with radiofrequency

fields have not been fully investigated.

Because there are suggestions that RF exposure may be more hazardous for thefetus and child due to their greater susceptibility, prudent avoidance is one

approach to keeping childrens exposure as low as possible.

Further research is needed to clarify the potential risks of ELF-EMF andradiofrequency fields for childrens health.

XII. International Agency for Research on Cancer (IARC)

A 2001 report by the WHO International Agency for Research on Cancer (IARC)

concluded that ELF-EMF power frequency fields are a Category 2B (Possible) Human

Carcinogen. These are power-frequency electromagnetic fields (50-Hz and 60-Hz

electric power frequency fields).

The World Health Organization (WHO) is conducting the International Electromagnetic

Fields (EMF) Project to assess health and environmental effects of exposure to static and

time varying electric and magnetic fields in the frequency range of 1300 gigahertz

(GHz). Project goals include the development of international guidelines on exposure

limits. This work will address radio and television broadcast towers, wireless

communications transmission and telecommunications facilities, and associated devices

such as mobile phones, medical and industrial equipment, and radars. It is a multi-year

program that began in 1996 and will end in 2005. www.who.int/peh-emf
http://www.who.int/peh-emfhttp://www.who.int/peh-emfhttp://www.who.int/peh-emf


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XIII. SCENIHR Opinion (European Commission Study of EMF and Human

Health)

An independent Scientific Committee on newly emerging risks commissioned by the

European Union released an update of its 2001 opinion on electromagnetic fields and

human health in 2007. The Committed addressed questions related to potential risks

associated with interaction of risk factors, synergistic effects, cumulative effects, anti-

microbial resistance, new technologies such as nanotechnologies, medical devices, tissue

engineeringm blood products, fertility reduction, cancer of endocrine organs, physical

hazards such as noise and electromagnetic fields and methodologies for assessing new

risks. SCENIHR, 2007

SCENIHR Conclusions onExtremely low frequency fields (ELF fields)

The previous conclusion that ELF magnetic fields are possibly carcinogenic,

chiefly based on childhood leukaemia results, is still valid. There is no generallyaccepted mechanism to explain how ELF magnetic field exposure may cause

leukaemia.

For breast cancer and cardiovascular disease, recent research has indicated that an

association is unlikely. For neurodegenerative diseases and brain tumours, the linkto ELF fields remains uncertain. A relation between ELF fields and symptoms

(sometimes referred to as electromagnetic hypersensitivity) has not been

demonstrated.

SCENIHR Conclusions on Radiofrequency Radiation fields (RF fields)

Since the adoption of the 2001 opinion, extensive research has been conducted

regarding possible health effects of exposure to low intensity RF fields. Thisresearch has investigated a variety of possible effects and has included

epidemiologic, in vivo, and in vitro research. The overall epidemiologic evidencesuggests that mobile phone use of less than 10 years does not pose any increased

risk of brain tumour or acoustic neuroma. For longer use, data are sparse, sinceonly some recent studies have reasonably large numbers of long-term users. Any

conclusion therefore is uncertain and tentative. From the available data, however,

it does appear that there is no increased risk for brain tumours in long-term users,with the exception of acoustic neuroma for which there is limited evidence of aweak association. Results of the so-called Interphone study will provide more

insight, but it cannot be ruled out that some questions will remain open.

SCENIHR Conclusions on Sensitivity of Children

Concerns about the potential vulnerability of children to RF fields have been


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raised because of the potentially greater susceptibility of their developing nervoussystem; in addition, their brain tissue is more conductive than that of adults since

it has a higher water content and ion concentration, RF penetration is greaterrelative to head size, and they have a greater absorption of RF energy in the

tissues of the head at mobile telephone frequencies. Finally, they will have a

longer lifetime exposure.

Few relevant epidemiological or laboratory studies have addressed the possibleeffects of RF field exposure on children. Owing to widespread use of mobile

phones among children and adolescents and relatively high exposures to the brain,investigation of the potential effect of RF fields in the development of childhood

brain tumour is warranted. The characteristics of mobile phone use amongchildren, their potential biological vulnerability and longer lifetime exposure

make extrapolation from adult studies problematic.

There is an ongoing debate on possible differences in RF absorption between children

and adults during mobile phone usage, e.g. due to differences in anatomy (Wiart et al.

2005, Christ and Kuster, 2005). Several scientific questions like possible differences of

the dielectric tissue parameters remain open. The anatomical development of the nervous

system is finished around 2 years of age, when children do not yet use mobile phones

although baby phones have recently been introduced. Functional development, however,

continues up to adult age and could be disturbed by RF fields.

XIV. Health Protection Agency (Formerly the NRPB - United Kingdom)

The National Radiation Protection Board or NRPB (2004) concluded, based on a review

of the scientific evidence, that the most coherent and plausible basis from which guidance

could be developed on exposures to ELF concerned weak electric field interactions in the

brain and CNS (NRPB, 2004). A cautious approach was used to indicate thresholds for

possible adverse health effects.

Health Effects - It was concluded from the review of scientific evidence (NRPB,2004b) that the most coherent and plausible basis from which guidance could be

developed on exposures to ELF EMFs concerned weak electric field interactionsin the brain and CNS (NRPB, 2004). A cautious approach was used to indicate

thresholds for possible adverse health effects.

The brain and nervous system operate using highly complex patterns of\electrical signals. Therefore, the basic restrictions are designed to limit the


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electric fields and current densities in these tissues so as to not adversely affecttheir normal functioning. The adverse effects that might occur cannot easily be

characterized according to presenting signs or symptoms of disease or injury.They represent potential changes to mental processes such as attention and

memory, as well as to regulatory functions with in the body. Thus, the basic

restrictions should not be regarded as precisely determined values below whichno adverse health effects can occur and above which clearly discernible effectswill happen. The do, however, indicate an increasing likelihood of effects

occurring as exposure increases above the basic restriction values.

From the results of the epidemiological investigations, there remain concernsabout a possible increased risk of child leukaemia associated with exposure to

magnetic fields above about 0.4 uT (4 mG). In this regard, it is important toconsider the possible need for further precautionary measures.

This recent statement by the UK Health Protection Agency clearly indicates that the

current guidelines may not be protective of public health. Yet, the reference levels used

in the United Kingdom remain at 5000 mG for 50 Hz power frequency fields for

occupational exposure and 1000 mG for public exposure.

XV. US Government Radiofrequency Interagency Working Group Guidelines

Statement

The United States Radiofrequency Interagency Working Group (RFIAWG) cited

concerns about current federal standards for public exposure to radiofrequency radiation

in 1999 (Lotz, 1999 for the Radiofrequency Interagency Working Group)

Studies continue to be published describing biological responses to nonthermal

ELF-modulated RF radiation exposures that are not produced by CW(unmodulated) radiation. These studies have resulted in concern that exposure

guidelines based on thermal effects, and using information and concepts (time-averaged dosimetry, uncertainty factors) that mask any differences between

intensity-modulated RF radiation exposure and CW exposure, do not directlyaddress public exposures, and therefore may not adequately protect the public.

The United States government Federal Radiofrequency Interagency Working Group has

reviewed the existing ANSI/IEEE RF thermal-based exposure standard upon which the

FCC limit is based. This Working Group was made up of representatives from the US

governments National Institute for Occupational Safety and Health (NIOSH), the


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Federal Communications Commission (FCC), Occupational Health and Safety

Administration (OSHA), the Environmental Protection Agency (US EPA), the National

Telecommunication and Information Administration, and the US Food and Drug

Administration (FDA).

On June 17, 1999, the RFIAWG issued a Guidelines Statement that concluded the present

RF standard may not adequately protect the public. The RFIAWG identified fourteen

(14) issues that they believe are needed in the planned revisions of ANSI/IEEE RF

exposure guidelines including to provide a strong and credible rationale to support RF

exposure guidelines. In particular, the RFIAWG criticized the existing standards as not

taking into account chronic, as opposed to acute exposures, modulated or pulsed radiation

(digital or pulsed RF is proposed at this site), time-averaged measurements that may erasethe unique characteristics of an intensity-modulated RF radiation that may be responsible

for reported biologic effects, and stated the need for a comprehensive review

of long-term, low-level exposure studies, neurological-behavioral effects and

micronucleus assay studies (showing genetic damage from low-level RF).

The existing federal standards may not be protective of public health in critical areas.

The areas of improvement where changes are needed include: a) selection of an adverse

effect level for chronic exposures not based on tissue heating and considering modulation

effects; b) recognition of different safety criteria for acute and chronic exposures at non-

thermal or low-intensity levels; c) recognition of deficiencies in using time-averaged

measurements of RF that does not differentiate between intensity-modulated RF and

continuous wave (CW) exposure, and therefore may not adequately protect the public.

As of 2007, requests to the RFIAWG on whether these issues have been satisfactorily

resolved in the new 2006 IEEE recommendations for RF public safety limits have gone

unanswered (BioInitiative Working Group, 2007).


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XVI. United Kingdom - Parliament Independent Expert Group Report (Stewart

Report)

The Parliament of the United Kingdom commissioned a scientific study group to evaluate

the evidence for RF health and public safety concerns. In May of 2000, the United

Kingdom Independent Expert Group on Mobile Phones issued a report underscoring

concern that standards are not protective of public health related to both mobile phone

use and exposure to wireless communication antennas.

Conclusions and recommendations from the Stewart Report (for Sir William Stewart)

indicated that the Group has some reservation about continued wireless technology

expansion without more consideration of planning, zoning and potential public health

concerns. Further, the Report acknowledges significant public concern over community

siting of mobile phone and other communication antennas in residential areas and near

schools and hospitals.

Children may be more vulnerable because of their developing nervous system,

the greater absorption of energy in the tissue of the head and a longer lifetime ofexposure.

The siting of base stations in residential areas can cause considerable concernand distress. These include schools, residential areas and hospitals.

There may be indirect health risks from living near base stations with a need formobile phone operators to consult the public when installing base stations.

Monitoring should be expecially strict near schools, and that emissions of

greatest intensity should not fall within school grounds.

The report recommends a register of occupationally exposed workers beestablished and that cancer risks and mortality should be examined to determine

whether there are any harmful effects.(IEGMP, 2000)


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XVII. Food and Drug Administration (US FDA)

The Food and Drug Administration announced on March 28, 2007 it is contracting with

the National Academy of Science to conduct a symposium and issue a report on

additional research needs related to possible health effects associated with exposure toradio frequency energy similar to those emitted by wireless communication devices. The

National Academy of Sciences will organize an open meeting of national and

international experts to discuss the research conducted to date, knowledge gaps, and

additional research needed to fill those gaps. The workshop will consider the scientific

literature and ongoing research from an international perspective in order to avoid

duplication, and in recognition of the international nature of the scientific community and

of the wireless industry.

Funding for the project will come from a Cooperative Research and Development

Agreement (CRADA) between the Food and Drug Administration's Center for Devices

and Radiological Health and the Cellular Telecommunications and Internet Association

(CTIA). http://www.fda.gov/cellphones/index.html

XVIII. National Institutes for Health - National Toxicology Program

The National Toxicology Program (NTP) is a part of the National Institute for

Environmental Health Sciences, National Institutes for Health. Public and agency

comment has been solicited on whether to add radiofrequency radiation to its list of

substances to be tested by NTP as carcinogens. In February 2000 the FDA made a

recommendation to the NPT urging that RF be tested for carcinogenicity

(www.fda.gov.us). The recommendation is based in part on written testimony stating:

Animal experiments are crucial because meaningful data will not be available

from epidemiological studies for many years due to the long latency periodbetween exposure to a carcinogen and the diagnosis of a tumor.

There is currently insufficient scientific basis for concluding either that wireless

communication technologies are safe or that they pose a risk to millions ofusers.
http://www.fda.gov/cellphones/index.htmlhttp://www.fda.gov/cellphones/index.html


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FCC radiofrequency radiation guidelines are based on protection from acute

injury from thermal effects of RF exposure and may not be protective against anynon-thermal effects of chronic exposures.

In March of 2003, the National Toxicology Program issued a Fact Sheet regarding itstoxicology and carcinogenicity testing of radiofrequency/microwave radiation. These

studies will evaluate radiofrequency radiation in the cellular frequencies.

The existing exposure guidelines are based on protection from acute injury fromthermal effects of RF exposure. Current data are insufficient to draw definitive

conclusions concerning the adequacy of these guidelines to be protective againstany non-thermal effects of chronic exposures.

XIX. US Food and Drug Administration

In February of 2000, Russell D. Owen, Chief of the Radiation Biology Branch of the

Center for Devices and Radiological Health, US Food and Drug Administration (FDA)

commented that there is:

currently insufficient scientific basis for concluding whether wirelesscommunication technologies pose any health risk.

Little is known about the possible health effects ofrepeated or long-term

exposures to low level RF of the sort emitted by such devices.

Some animal studies suggest the possibility for such low-level exposures toincrease the risk of cancer

Dr. Owens comments are directed to users of cell phones, but the same questions are

pertinent for long-term RF exposure to radiofrequency radiation for the larger broadcast

transmissions of television, radio and wireless communications (Epidemiology Vol. 1,

No. 2 March 2000 Commentary). The Food and Drug Administration signed an

agreement (CRADA agreement) to provide funding for immediate research into RF

health effects, to be funded by the Cellular Telephone Industry of America. The FDA no

longer assures the safety of users.No completion date has been set.

XX. National Academy of Sciences - National Research Council


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An Assessment of Non-Lethal Weapons Science and Technology by the Naval Studies

Board, Division of Engineering and Physical Sciences (National Academies Press (2002)

has produced a report that confirms the existence of non-thermal bioeffects from

information transmitted by radiofrequency radiation at low intensities that cannot act by

tissue heating (prepublication copy, page 2-13).

In this report, the section on Directed-Energy Non-Lethal Weapons it states that:

The first radiofrequency non-lethal weapons, VMADS, is based on a biophysicalsusceptibility known empirically for decades. More in-depth health effects studies were

launched only after the decision was made to develop that capability as a weapon. The

heating action of RF signals is well understood and can be the basis for severaladditional directed-energy weapons. Leap-ahead non-lethal weapons technologies willprobably be based on more subtle human/RF interactions in which the signal information

within the RF exposure causes an effect other than simply heating: for example, stun,seizure, startle and decreased spontaneous activity. Recent developments in the

technology are leading to ultrawideband, very high peak power and ultrashort signalcapabilities, suggesting the the phase space to be explored for subtle, uyet potentially

effective non-thermal biophysical susceptibilities is vast. Advances will require adedicated effort to identify useful susceptibilities.

Page 2-13 of the prepublication report (emphasis added)

This admission by the Naval Studies Board confirms several critical issues with respect

to non-thermal or low-intensity RF exposures. First, it confirms the existence of

bioeffects from non-thermal exposure levels of RF. Second, it identifies that some of

these non-thermal effects can be weaponized with bioeffects that are incontrovertibly

adverse to health (stun, seizure, startle, decreased spontaneous activity). Third, it

confirms that there has been knowledge for decades about the susceptibility of human

beings to non-thermal levels of RF exposure. Fourth, it provides confirmation of the

concept that radiofrequency interacts with humans based on the RF information content

(signal information) rather than heating, so it can occur at subtle energy levels, not at

high levels associated with tissue heating. Finally, the report indicates that a dedicated

scientific research effort is needed to really understand and refine non-thermal RF as a

weapon, but it is promising enough for continued federal funding.


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XXI. The IEEE (United States)

IEEE ICES SCC-28 SC-4 Subcommittee (Radiofrequency/Microwave Radiation)

Members of the ICES SCC-28 SC-4 committee presented their views and justifications in

a Supplement to the Bioelectromagnetics Journal (2003). It offers a window into thethinking that continues to support thermal-only risks, and on which the current United

States IEEE recommendations have been made. The United States Federal

Communications Commission (FCC) has historically based its federally-mandated public

and occupational exposure standards on the recommendations of the IEEE.

Radiofrequency/Microwave Radiation

IEEEs original biological benchmark for setting human exposure standards (on which

most contemporary human standards are based) is disruption of food-motivated learned

behavior in subject animals. For RF, it was based on short, high intensity RF exposures

that were sufficient to result in changes in animal behavior.

The biological endpoint on which most contemporary standards are based isdisruption of food- motivated learned behavior in subject animals. The threshold

SAR for behavioral disruption has been found to reliably occur between 3 and 9W/kg across a number of animal species and frequencies; a whole-body average

SAR of 4 W/kg is considered the threshold below which adverse effects would not

be expected. To ensure a margin of safety, the threshold SAR is reduced by a safetyfactor of 10 and 50 to yield basic restrictions of 0.4 W/kg and 0.08 W/kg forexposures in controlled (occupational) and uncontrolled (public) environments,

respectively. (Osepchuk and Petersen, 2003).

The development of public exposure standards for RF is thus based on acute, but not

chronic exposures, fails to take into account intermittent exposures, fails to consider

special impacts of pulsed RF and ELF-modulated RF, and fails to take into account

bioeffects from long-term, low-intensity exposures that may lead to adverse health

impacts over time.


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XXII. BEMS Supplement 6 (Journal of the Bioelectromagnetics Society)

BEMS Supplement 6 was prepared in support of the IEEE SC-4 committee RF

recommendations. In explaining and defending revised recommendations on RF limits

contained within C.95.1, some key members took out space in Bioelectromagnetics (theJournal of the Bioelectromagnetic Society) to present papers ostensibly justifying a

relaxation of the existing IEEE RF standards, rather than making the standards more

conservative to reflect the emerging scientific evidence for both bioeffects and adverse

health impacts.

Several clues are contained in the BEMS Supplement 6 to understand how the SC-4 IEEE

C.95 revision working group and the ICES could arrive at a decision to not to recommend

tighter limits on RF exposure. Not one but two definitions of adverse effect are

described, one by Osepchuk/Petersen (2003) and another by the working group itself

(DAndrea et al, 2003). Both set a very high bar for demonstration of proof, and both are

ignored in the final recommendations by the SC-4 Subcommittee.

Second, many of the findings presented in the papers by individual authors in the BEMS

Supplement 6 do report that RF exposures are linked to bioeffects and to adverse effects;

but these findings are evidently ignored or dismissed by the SC-4 Subcommittee, ICES

and by the eventual adoption of these recommendations by the full IEEE membership (in

2006). Even with a very high bar of evidence set by the SC-4 Subcommittee (and two

somewhat conflicting definitions of adverse effect against which all scientific papers

were reviewed and analyzed); there is clear sign that the deal was done regardless of

even some of the key Subcommittee member findings reporting such effects at exposure

levels below the existing limits.* sidebar

The SC-4 Subcommittee has developed a new and highly limited definition on RF

effects, adverse effects and hazards that is counter to the WHO Constitution Principle on

Health. The definition as presented by DAndrea et al (2003, page S138) is based on the

SC-4 IEEE C.95 revision working group definition of adverse effect:


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An adverse effect is a biological effect characterized by a harmful change in health.For example, such changes can include organic disease, impaired mental function,

behavioral disfunction, reduced longevity, and defective or deficient reproduction.Adverse effects do not include: biological effects without detrimental health effect,

changes in subjective feelings of well-being that are a result of anxiety about RF effects

or impacts of RF infrastructure that are not related to RF emissions, or indirect effectscaused by electromagnetic interference with electronic devices. An adverse effectsexposure level is the condition or set of conditions under which an electric, magnetic or

electromagnetic field has an adverse effect.

Further, the working group extended its definition to include that of Michaelson and Lin

(1987) which states:

If an effect is of such an intense nature that it compromises the individuals ability to

function properly or overcomes the recovery capability of the individual, then the effectmay be considered a hazard. In any discussion of the potential for biological effects

from exposure to electromagnetic energies we must first determine whether any effectcan be shown; and then determine whether such an observed effect is hazardous.

The definition of adverse effect according to Osepchuk and Petersen (2003) reported in

the same BEMS Supplement 6 is:

An adverse biological response is considered any biochemical change, functional

impairment, or pathological lesion that could impair performance and reduce the abilityof an organism to respond to additional challenge. Adverse biological responses shouldbe distinguished from biological responses in general, which could be adaptive or

compensatory, harmful, or beneficial.

In contrast, the World Health Organization draft framework has accepted definitions ofbioeffect, adverse health effect and hazard (WHO EMF Program Framework for

Developing EMF Standards, Draft, October 2003). These definitions are not subject tothe whim of organizations preparing public exposure standard recommendations. The

WHO definition states that:

(A)nnoyance or discomforts caused by EMF exposure may not be pathological per se,but, if substantiated, can affect the physical and mental well-being of a person and the

resultant effect may be considered as an adverse health effect. A health effect is thusdefined as a biological effect that is detrimental to health or well-being. According to the

WHO Constitution, health is a state of complete physical, mental, and social well-beingand not merely the absence of disease or infirmity.

The SC-4 definitions require proof that RF has caused organic disease or other cited


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effects that qualify. The burden of proof is ultimately shifted to the public, that bears the

burden of unacknowledged health effects and diseases, where the only remedy is proof of

illness over a large population of affected individuals, over a significant amount of time,

and finally, delays until revisions of the standards can be implemented. The results of

studies and reviews in the BEMS Supplement 6 already acknowledge the existence of

bioeffects and adverse effects that occur at non-thermal exposure levels (below current

FCC and ICNIRP standards that are supposedly protective of public health. However,

they go on to ignore their own findings, and posit in advance that adverse effects seen

today will, even with chronic exposure, not conclusively reveal disease or dysfunction

tomorrow at exposure levels below the existing standards.

Sidebar: Quotes from BEMS Supplement 6

a) Studies and reviews where bioeffects likely to lead to adverse healtheffects with chronic exposure are reported;

b) adverse effects which are already documented;c) studies where non-thermal RF effects are reported and unexplained;

d) effects are occurring below current exposure limits, ande) conclusions by authors they cannot draw conclusions about hazards to

human health

These quotes appear in articles presented by the IEEE SC-4 Subcommittee in BEMS

Supplement 6. Despite these acknowledged gaps in information, lack of consistency in

studies, abundant conflicting evidence documenting low level RF effects that can

resulting serious adverse health impacts (DNA damage, cognitive impairment,

neurological deficits, cancer, etc), and other clear instances of denial of ability to predict

human health outcomes, the IEEE SC-4 Subcommittee has proposed recommendations to

relax the existing limits.


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XXIII. Proceedings of the NATO Advanced Research WorkshopMechanisms of

the Biological Effect on Extra High Power Pulses (EHPP) and

UNESCO/WHO/IUPAB Seminar Molecular and Cellular Mechanisms of

Biological Effects of EMF held March 2005, Yerevan, Armenia.

The proceedings conclude that the authors agreed with one main conclusion from thesemeeting(s): that in the future worldwide harmonization of standards have to be based on

biological responses, rather than computed values. The authors included 47 scientists,

engineers, physicians and policy makers from 21 countries from Europe, North and South

America, and Asia.

The ICNIRP Guidelines for radiofrequency electromagnetic exposure are based

only on thermal effects, and completely neglects the possibility of non-thermaleffect.

The guidelines of the International Commission on Non-Ionizing Radiation

Protection (ICNIRP) specify the quantative characteristics of EMF used to specifythe basic restrictions are current density, specific absorption rate (SAR) and

power density, i.e., the energetic characteristics of EMF. However, experimentaldata on energy-dependency of biological effects by EMF have shown that the SAR

approach, very often, neither adequately describes or explains the real value ofEMF-induced biological effects on cells and organisms, for at least two reasons:

a) the non-linear character of EMF-induced bioeffects due to the existence ofamplitude, frequency and exposure time-windows and b) EMF-induced

bioeffects significantly depend on physical and chemical composition of the

surrounding medium. (Preface pages XIXIII).


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